The Fourth Circuit Court of Appeals has upheld a lower court's decision to dismiss a lawsuit filed by American Acceptance Corporation of South Carolina (AAC) against the Lexington County Sheriff’s Department (LCSD). The case revolves around the seizure of two motorcycles that AAC financed, which were taken as evidence in a murder investigation. The ruling is significant as it clarifies the due process rights of third-party lienholders when law enforcement retains property during ongoing criminal investigations.

AAC, which finances the acquisition of vehicles, claimed that LCSD violated its procedural due process rights by not notifying it about the seizure of the motorcycles. The court's decision, issued on May 12, 2026, affects how law enforcement agencies handle evidence and the rights of lienholders in similar situations.

Background

The dispute began when AAC financed two Harley-Davidson motorcycles owned by Timothy Harold Brock and Shane Adam Andrzejewski. Both individuals had defaulted on their payments when LCSD seized the motorcycles as evidence related to a criminal investigation into Brock's murder. Brock was killed in a shootout involving motorcycle gangs, and Andrzejewski was later arrested and charged in connection with the incident.

After the motorcycles were taken, AAC learned of the seizures through media reports rather than direct communication from LCSD. The company sought to reclaim the motorcycles through legal action, arguing that it had not been given notice or an opportunity to be heard regarding the seizures. AAC's initial attempts to recover the motorcycles in state court were unsuccessful, leading to its federal lawsuit under 42 U.S.C. § 1983, claiming a violation of its due process rights.

The Ruling

The Fourth Circuit affirmed the district court's dismissal of AAC's claims. The court found that the initial seizure of the motorcycles was lawful under the Fourth Amendment, which governs searches and seizures. Judge Patricia Tolliver Giles, writing for the panel, stated, "LCSD had a reasonable basis to retain [the motorcycles] as evidence for Andrzejewski’s pending charges and Brock’s murder investigation." The court ruled that AAC's property interest in the motorcycles did not outweigh the government's need to retain evidence for a criminal investigation.

The judges concluded that the Fourth Amendment defined the due process owed to AAC, stating that in criminal matters, the need for prompt action often justifies the absence of notice or a hearing. The court emphasized that requiring further due process would hinder law enforcement's ability to conduct investigations effectively.

Impact

This ruling has important implications for lienholders and law enforcement agencies. It clarifies that when property is seized as evidence in a criminal investigation, the due process requirements may be less stringent than in other contexts. The decision suggests that law enforcement can retain evidence without notifying third-party lienholders, as long as the seizure complies with the Fourth Amendment.

The court's ruling may set a precedent for similar cases in the future, reinforcing the idea that law enforcement's need to preserve evidence can take precedence over the rights of property owners or lienholders. This could lead to more challenges for individuals and companies seeking to reclaim property seized during criminal investigations.

What's Next

AAC has the option to appeal the ruling to the Supreme Court, but it is unclear if they will pursue that route. There are no related cases pending that directly address this issue in the same context.